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On 17 June 2026, the United States and Iran signed a Memorandum of Understanding that marks the most significant shift in Iran's international standing in nearly a decade. The 14-point MOU, released by both sides, provides for a sanctions moratorium and a 60-day negotiating period toward a comprehensive final agreement.
Under its immediate terms, waivers have been granted for Iranian crude oil exports, petroleum products, and associated banking, insurance, and shipping services, allowing Iran to re-enter global energy markets.
However, comprehensive relief, including the termination of UN Security Council resolutions and unilateral US measures, remains conditional, deferred to the final agreement, and contingent on IAEA verification of Iran's nuclear commitments.
For businesses seeking first-mover advantage, the opportunity is real, but so is the complexity. Our team is closely monitoringthese developments to guide clients through the evolving risk landscape.
What has changed immediately
The immediate waivers are targeted and sector-specific.
On 22 June 2026, the US Treasury's Office of Foreign Assets Control (OFAC) implemented the MOU's commitments by issuing Iran-related General License X.
This authorises transactions "ordinarily incident and necessary to the production, sale, delivery, or offloading of crude oil, petrochemical products, or petroleum products of Iranian origin". The licence is valid through 21 August 2026.
This immediate relief is designed to stabilise global energy markets and restore freedom of navigation through the Strait of Hormuz, which the US has committed to fully opening within 30 days.
What has not changed
Comprehensive sanctions relief remains conditional and deferred.
Restrictions across manufacturing, technology, consumer goods, and the wider financial sector remain firmly in place pending the outcome of the 60-day negotiations and ongoing IAEA verification of Iran'snuclear programme.
Critically for businesses and their advisers operating outside the United States, UK and EU sanctions frameworks are not aligned with the US MOU.
The EU reimposed "snapback" sanctions in September 2025, and UK sanctions, administered by the Office of Financial Sanctions Implementation (OFSI) under the Iran (Sanctions) Regulations 2023, continue to apply. For the foreseeable future engaging with any Iran-connected counterparty without a jurisdiction-specific sanctions analysis carries significant legaland regulatory risk.
What businesses need now
Any Iran-related engagement requires a structured compliance approach. The temporary nature of the current relief and the absence of a final agreement mean that compliance programmes must be both robust and adaptable.
Counterparty due diligence: Extending beyond basic SDN list screening to include comprehensive ownership tracing (including Hong Kong, BVI, and Panama-incorporated entities) and IRGC nexus analysis. Recent US enforcement actions have targeted a wide network of shadow fleet operators, financial facilitators, and Chinese refineries, demonstrating the risks associated with opaque ownership structures.
Jurisdictional advice: Covering US, UK and EU regulatory frameworks. The US, UK, and EU regimes are not aligned, and each requires a separate analysis.
Licensing guidance: Including OFSI licences for UK-connected persons and entities where activities are not covered by the temporary US relief.
Transaction structuring: To ensure ongoing compliance as the sanctions landscape evolves, and to navigate potential pitfalls such as the continuing restrictions on dealings with the IRGC.
At Dransfield Partners, we are advising clients on how to build compliance frameworks that are "future-proofed" for the post-sanctions era. Our team provides integrated advice across sanctions, trade finance, and corporate structuring, ensuring our clients can navigate the complexities of this transitional period with confidence.
